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that Mr. Boykens, a certified public accountant, thought that
their “untaxing” idea was “crazy.”
We find petitioners’ explanations of their “firm belief” not
credible. Mr. Runkle had a paralegal degree and had the
intelligence to research the law and understand the statutes. He
demonstrated this ability at the summons conference when he
explained that he had already researched section 6001 and this
section did not require him to file a return. Petitioners’
actions and correspondence reveal that their belief was not an
honest misunderstanding of complex provisions of the Code.
Instead, it reveals they knew they were required to file returns
but failed to do so. Their asserted belief that the tax law
should not apply is an insufficient defense to fraud. See Cheek
v. United States, 498 U.S. 192, 205-206 (1991); Niedringhaus v.
Commissioner, 99 T.C. at 219.
8. Summary of the Badges of Fraud
Most of the badges of fraud upon which this Court
customarily relies are present in this case. Petitioners engaged
in a pattern of failing to file income tax returns despite having
the business acumen and knowledge they had sufficient income to
require them to file tax returns. They filed tax returns for
others but not themselves during the years at issue, and they
stopped filing tax returns for themselves after more than 20
years filing for themselves. In addition, they deliberately
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